Last Updated: July 23, 2017
The Program Practice (“TPP”), wants you to enjoy and benefit from our website and online services secure in the knowledge that we have implemented fair information practices designed to protect your privacy. TPP owns and operates the public-facing website, www.theprogrampractice.com, as well as makes the same or similar content available to mobile users, including via apps available to users of Android, iPhone, iPad or any other mobile device (collectively the "Site").
What Information Is Collected?
We collect content/information (“Content”) when you use our Site, including when you sign up for an account. We also collect information about how you use our Site, such as the types of Content you view or the frequency and duration of your activities on the Site.
We collect information from and about the devices where you install or access the Site. We may associate information we collect, which includes: operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers; device location, including specific geographic locations; connection information, such as the name of your mobile operator, browser type, language and time zone, mobile number and IP address. We also receive information about you and your activities from a partner when we jointly offer services.
We collect two basic types of information from you in conjunction with your use of the Site: non-personally identifiable information and personally identifiable information. Non-personally identifiable information does not individually identify you, but it may include tracking and usage information about your general location, demographics, use of the Sites and the Internet. Personally identifiable information is any information that can individually identify you and includes, your name, address, phone number, and email address, or non-personally identifiable information that has been linked to such personally identifiable information.
You have the ability to update and/or delete your account information at any time. To do so, simply click "login" located at the top of each page, and then select "account info." Your account information will be displayed, and you will have the ability to edit, change, or delete any information. Additionally, should you so desire, you may change or delete any of your personal information on file at TPP by sending an email request to us at email@example.com. Please be sure to include your full name, physical address and e-mail address in any correspondence.
Personally Identifiable Information
As a general matter, you can browse the Site without submitting your personally identifiable information to us. However, there are a number of circumstances in which you may supply us with your personally identifiable information, including when you subscribe to our publications, newsletters, and other content; set up an account/profile; place an order; register for an event; register for services; register for a site or any part thereof; complete a survey or participate in market research; enter a contest; upload content; send us an email; or when you seek employment at TPP. Additionally, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or charge card number, or other payment information, as well as your name, telephone number(s), email and/or street address, and other personally identifiable information. Other information such as your age, gender, an avatar, and the number for your mobile or other device may also be requested. In addition, you may be asked to send us similar information via messaging (e.g., email, SMS, MMS, or other technologies).
Non-Personally Identifiable Information
When you interact with the Site, we may collect certain information that does not identify you individually (“non-personally identifiable information” or “non-PII”), such as demographic data, information about your computer, mobile device, or other device that you use to access the Site, including IP address, general location information, unique device identifiers, browser type, browser language, and other transactional information. We may also collect information about your use of the Site, including your search terms and search results, and additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses. Our servers or hosting company may automatically keep an activity log of your use of our Site. In addition to non-identifiable individual information, we may collect aggregate data regarding the use of the Sites.
TPP User Generated Content and Public Activities
We may offer you opportunities to engage in public activities on the Site. Public activities are any actions you take on the Site that are designed to be visible to other users, including comments, recommendations, reviews, ratings, or any other items that you submit. Any information you disclose in your public activities, along with your screen name or ID, or any image or photo, becomes public and may be used by TPP for online and offline promotional or commercial uses in any and all media. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these areas. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions.
Public activities may be included in our RSS feeds, APIs and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds. Keep in mind that we are not responsible for any personal information you choose to make public via your public activities, and you agree that such sharing will be deemed to have been done by you, not TPP.
Collection of Your Source IP Address/Location Information
We collect and store your device’s source Internet Protocol (“IP”) address which may disclose the general location of your device at the time you access the Site, your company or your university or your Internet Service Provider. Advertisements and certain content may be directed to you as a result of this data. We may use your IP address to help diagnose problems with our servers, gather broad demographic information, and administer the Site.
Collection of Personally Identifiable Information From Events
We receive personally identifiable information about attendees to our online events and promotions from sign-in and registration lists. We may use this information ourselves and share with event or promotion sponsors.
We may also use web beacons and web storage technologies. A web beacon (also known as an “action tag”, “tracer tag”, or “single-pixel gif”) is an invisible graphic on a web page that is programmed to collect information about your use of a given website. Web Storage is a feature in some browsers that permits websites to store data within your browser rather within a cookie. We do not share or provide personally identifiable information we may collect in web beacons or store in web storage, such as names, e-mail addresses and phone numbers, to unaffiliated third parties without your express permission.
Third-party ad serving companies and other unaffiliated advertisers may also display advertisements on our site. As part of their service, they may place a separate cookie on your computer or utilize other data collection and tracking technologies, to collect information such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to a particular advertisement. We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect and we are not responsible for the privacy policies or the content of those third parties. Please visit the sites of those businesses to review their privacy policies.
How Do We Use Your Information?
We use the information we learn from you to help us personalize and continually improve your experience on the Site, including to:
- Provide you with the content, products and services you request
- Post your user generated content to our Site as you request
- Communicate with you about your account or transactions with us and send you information about features and enhancements on or to our Site
- Communicate with you about changes to our policies
- Communicate with you about your comment to a story or topic
- Personalize content and experiences on our Site, including providing you recommendations based on your preferences
- Send you newsletters, offers and promotions for our products and services, third party products and services, or special events by e-mail, text, or other mediums
- Provide you with advertising, including advertising based on your activity on our Site or activity on third party sites and applications
- Administer our loyalty or incentive programs
- Administer contests, sweepstakes, promotions, and surveys
- Optimize or improve our products, services and operations
- Detect, investigate, and prevent activities that may violate our policies or be illegal
- Perform statistical, demographic, and marketing analysis of users of the Site and their purchasing patterns
Who Can See Your Information?
We have third-party agents, subsidiaries, affiliates and partners that perform functions on our behalf, including, but not limited to, hosting, content syndication, content management tools, social media integration, marketing, analytics, billing and customer service. These entities may have access to personally identifiable information if needed to perform their functions. If such access is required, the third parties will be obligated to maintain the confidentiality and security of that personally identifiable information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Site.
Business Partners and Other Third Parties
From time to time we allow companies whose products or services we feel may interest our users to advertise to those users, using the names and addresses provided to us during the process of subscribing to a TPP publication or service. We may share our subscribers’ names and addresses directly with these companies or use a third party to administer the process on our behalf. Many of our subscribers find this a valuable and time-saving service. If you do not want your name and address to be shared for these purposes, you can opt-out of such sharing by e-mailing us at firstname.lastname@example.org, or calling or writing us at the contact information provided.
Law Enforcement, Legal Process, and Emergency Situations
In some cases, we may use or disclose your personally identifiable information to a third party if we are required to do so by law or if we in good faith believe that such action is necessary to comply with the law or legal process such as the Electronic Communications Privacy Act or the Child Online Privacy Act; to protect and defend our rights or to prevent misuse of our Site; or to protect the personal safety of our employees, agents, partners, the users of the Site, or the public.
Use of Non-Personally Identifiable Information
We may disclose or share individual, non-personally identifiable information and aggregate information in any manner other than that described herein that we deem appropriate or necessary. Among other things, we will disclose non-personally identifiable information to third parties to help us determine how people use parts of the Site and who our users are so we can improve our Site. We will also disclose non-personally identifiable information to our partners and other third parties about how our users collectively use the Site.
What Are Your Choices?
We believe you should have choices about the collection, use and sharing of your information. Although you cannot opt-out of all data collection when you visit our Site, you can limit the collection, use and sharing of your information.
Collection of Personally Identifiable Information
All personally identifiable information is provided on a voluntary basis. If you do not want TPP to collect such information, you should not submit it to the Site. However, doing so will restrict your ability to access some content and use some of the functionality of the Site.
Sharing of Personally Identifiable Information
You may opt-out of having your personally identifiable information shared with business partners and third parties for marketing and advertising purposes by e-mailing us at email@example.com or contacting us at the phone numbers or postal address provided below.
Online, Interest Based Advertising
You may be able to opt-out of the use of your information for online, interest based advertising from participating advertising partners and unaffiliated third parties through the Network Advertising Initiative’s opt-out program by clicking http://www.networkadvertising.org/managing/opt_out.asp.
Emails and Newsletters
You may always opt-out of receiving future e-mail marketing messages and newsletters from TPP by following the instructions contained within the emails and newsletters, or by e-mailing, calling or writing us at the addresses below.
Governing Law & Notice to Non-U.S. Users
How Your Information Is Secured
We take reasonable security measures to protect your information, including the use of physical, technical and administrative controls. Please understand, however, that while we try our best to safeguard your personally identifiable information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. You need to help protect the privacy of your own information. You must take precautions to protect the security of any personally identifiable information that you may transmit over any home networks, wireless routers, wireless (WiFi) networks or similar devices by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personally identifiable information. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks.
The time period for which we keep information varies according to the purpose for which it is used. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.
In the unlikely event that we believe that the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you via your computer, mobile or other device.
Responsible Disclosure of Security Vulnerabilities
No technology is perfect, and TPP believes that working with skilled security researchers across the globe is crucial in identifying weaknesses in any technology. If you believe you've found a security issue in our product or service, we encourage you to notify us. We welcome working with you to resolve the issue promptly.
Let us know as soon as possible upon discovery of a potential security issue, and we'll make every effort to quickly resolve the issue. Provide us a reasonable amount of time to resolve the issue before any disclosure to the public or a third-party. Make a good faith effort to avoid privacy violations, destruction of data, and interruption or degradation of our service. Only interact with accounts you own or with explicit permission of the account holder.
While researching, refrain from: Denial of service; Spamming; Social engineering (including phishing) of TPP staff or contractors; Any physical attempts against TPP property or data centers. While we currently do not have a formal vulnerability reporting system in place at this time, please reach out to firstname.lastname@example.org to report any critical issues you may discover. Thank you for helping keep TPP and our users safe.
Contests, Sweepstakes, Events or Promotions
The Site is not intended for children under 13 years of age. TPP does not knowingly collect personal information from children under 13 years of age. If you are under 13 years of age, do not provide personal information to The Program Practice without providing us with consent from your parents. If TPP discovers that a child under the age of 13 has provided TPP personal information and we do not have parental consent, TPP will immediately delete that child’s information from the Site. If you believe that TPP has been provided with the personal information of a child under the age of 13 without parental consent, please notify us immediately at email@example.com.
Your California Privacy Rights
California Civil Code Section 1798.83 permits visitors and customers of TPP who are California residents to request and obtain from TPP once a year, free of charge, certain information regarding its disclosure of their personally identifiable information to third parties for their direct marketing purposes during the prior calendar year. In response to your written request, TPP is allowed to, instead, provide you with a cost-free means to opt-out of such sharing, or a “Customer Choice Notice”. TPP has chosen to provide you with a cost-free means to opt-out of such sharing. To make such a request, please send an e-mail to firstname.lastname@example.org specifying that you seek to opt-out of the sharing of your personal information with third parties for marketing purposes. Please allow thirty days for a response. It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.
Questions About this Policy; Access to Your Information
United States Postal Service:
The Program Practice
244 Fifth Avenue Suite # E247
New York, NY 10001
The contact information provided to request access or changes to your personally identifiable information; however, you will not be permitted to examine the personally identifiable information of any other person or entity and may be required to provide us with personally identifiable information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete personally identifiable information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.